OFAC Takes Further Action Related to Crimea

Joan Koenig and Mollie D. Sitkowski

On December 30, 2014, the Office of Foreign Assets Control (OFAC) in the Department of the Treasury issued General License No. 5 to authorize certain prohibited activities in order to wind down operations involving the Crimea Region of Ukraine to address activities prohibited by Executive Order 13685, issued on December 19, 2014.

EO 13685 created a comprehensive embargo against Crimea, prohibiting all exports of goods and services to, and imports from, Crimea, and added individuals to the Specially Designated Nationals (SDN) list. General License No. 4, also issued on December 19, authorized the exportation or reexportation of agricultural commodities, medicine, and medical supplies and their replacement parts.

The Ukraine Freedom Support Act of 2014 was also signed into law on December 18, 2014. The act sets the stage of mandatory sanctions in the next few months and authorizes other sanctions contingent on specified facts and circumstances.

It appears that the United States and the EU coordinated on the issuance of new Ukraine-related sanctions, as the EU expanded its sanctions on Crimea on December 18th as well. The EU’s new sanctions prohibit, among other things, investments in Crimea and Sevastopol, the buying of real estate in Crimea, and the exportation of certain types of goods.

For more information on how these new sanctions and general licenses may affect your company, please contact one of the authors above.